We, Ownership Asset Management Services GmbH (hereinafter: "the company", "we" or "us") take the protection of your personal data seriously and would like to inform you here about data protection in our company.
Within the scope of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: "GDPR") in order to ensure the protection of personal data of the data subject (we will also refer to you as "customer", "user", "you", "you" or "data subject").
Following the example of Art. 4 of the GDPR, this data protection notice is based on the following definitions:
- "Personal data" (Art. 4 No. 1 DS-GVO) means any information relating to an identified or identifiable natural person ("data subject"). An individual is identifiable if he or she can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information relating to his or her physical, physiological, genetic, mental, economic, cultural or social identity characteristics. The identifiability can also be given by means of a linkage of such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photographs, video or audio recordings may also contain personal data).
- "Processing" (Art. 4 No. 2 GDPR) means any operation which involves the handling of personal data, whether or not by means of automated (i.e. technology-assisted) processes. This includes, in particular, the collection (i.e. acquisition), recording, organization, classification, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, as well as the change of a purpose or intended use on which a data processing was originally based.
– "Controller" (Art. 4 No. 7 GDPR) means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- "Third party" (Art. 4 No. 10 GDPR) means any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who are authorized to process the personal data under the direct responsibility of the controller or processor; this also includes other group-affiliated legal entities.
(2) Name and Address of the Controller
The controller of your personal data within the meaning of Art. 4 No. 7 DS-GVO is us:
Ownership Asset Management Services GmbH
20355 Hamburg, Deutschland
Tel.: +49 40 32524416
For further information about our company, please refer to the imprint information on our website [link to imprint].
(3) Contact Details of the Data Protection Officer
Our company data protection officer is available at all times to answer any questions you may have and to act as your contact person about data protection at our company. His contact details are:
Ownership Asset Management Services GmbH
20355 Hamburg, Deutschland
Tel.: +49 40 32524416
(4) Legal Basis for Data Processing
In principle, any processing of personal data is prohibited by law and only permitted if the data processing falls under one of the following justifications:
The storage of information in the end user's terminal equipment or access to information already stored in the terminal equipment is only permitted if it is covered by one of the following justifications:
In the following, we will indicate the applicable legal basis for each of the processing operations carried out by us. Processing may also be based on several legal bases.
(5) Data Erasure and Storage Period
For the processing operations carried out by us, we indicate below in each case how long the data will be stored by us and when it will be deleted or blocked. If no explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for the storage no longer applies. In principle, your data will only be stored on our servers in Germany, subject to a possible transfer in accordance with the regulations in A.(7) and A.(8).
However, storage may take place beyond the specified time in the event of a (threatened) legal dispute with you or other legal proceedings or if storage is provided for by legal regulations to which we are subject as the responsible party (e.g. § 257 HGB, § 147 AO). If the storage period prescribed by the statutory provisions expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for this.
(6) Data Security
We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties, taking into account the state of the art, implementation costs and the nature, scope, context and purpose of the processing, as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.
We will be happy to provide you with more detailed information on request. Please contact our data protection officer (see A.(3)).
(7) Cooperation with Processors
As with any larger company, we also use external domestic and foreign service providers (e.g. for IT, logistics, telecommunications, sales and marketing) to process our business transactions. These service providers only act on our instructions and have been contractually obligated to comply with data protection regulations in accordance with Art. 28 DS-GVO.
If we pass on your personal data to our subsidiaries or if our subsidiaries pass it on to us (e.g. for advertising purposes), this is done on the basis of existing contractual relationships.
(8) Conditions for the Transfer of Personal Data to Third Countries
In the course of our business relationships, your personal data may be transferred or disclosed to third party companies. These may also be located outside the European Economic Area (EEA), i.e. in third countries. Such processing takes place exclusively for the fulfillment of contractual and business obligations and for the maintenance of your business relationship with us (legal basis is Art. 6 para. 1 lit. b or lit. f in each case in conjunction with Art. 44 et seq. Art. 44 ff. DS-GVO). We will inform you about the respective details of the transfer in the following at the relevant points.
The European Commission certifies that some third countries have a level of data protection comparable to the EEA standard by means of so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is adequately guaranteed. This is possible via binding company regulations, standard contractual clauses of the European Commission for the protection of personal data pursuant to Art. 46 Para. 1, 2 lit. c DS-GVO (the standard contractual clauses of 2021 are available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021 D0915&locale-en), certificates or recognized codes of conduct. Please contact our data protection officer (see under A. (3)) if you would like more information on this.
(9) No Automated Decision-Making (including profiling)
We do not intend to use any personal data collected from you for any automated decision-making process (including profiling).
(10) No Obligation to Provide Personal Data
We do not make the conclusion of contracts with us dependent on you providing us with personal data in advance. As a customer, you are under no legal or contractual obligation to provide us with your personal data; however, we may only be able to provide certain services to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case in the context of the products offered by us presented below, you will be informed of this separately.
(11) Legal Obligation to Transfer Certain Data
We may be subject to a specific legal or statutory obligation to provide lawfully processed personal data to third parties, in particular public bodies (Art. 6 para. 1 sentence 1 lit. c DS-GVO).
(12) Your Rights
You can assert your rights as a data subject regarding your processed personal data at any time by contacting us using the contact details provided at the beginning of A.(2). As a data subject, you have the right to:
- in accordance with Art. 15 DS-GVO to request information about your data processed by us. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or opposition, the existence of a right of objection, the origin of your data, if it was not collected by us, as well as the existence of automated decision-making, including profiling and, if applicable, meaningful information about its details;
- in accordance with Art. 16 DS-GVO, to demand the correction of incorrect or the completion of your data stored by us without delay;
- pursuant to Art. 17 DS-GVO, to request the deletion of your data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims;
- in accordance with Art. 18 DS-GVO, to demand the restriction of the processing of your data, insofar as the accuracy of the data is disputed by you or the processing is unlawful;
- pursuant to Art. 20 DS-GVO, to receive your data that you have provided to us in a structured, common and machine-readable format or to request the transfer to another controller ("data portability");
- object to processing pursuant to Art. 21 DS-GVO, provided that the processing is based on Art. 6 (1) p. 1 lit. e or lit. f DS-GVO. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, when exercising such an objection, we ask you to explain the reasons why we should not process your data as we have done. In the event of your justified objection, we will review the situation and either discontinue or adjust the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing;
- in accordance with Art. 7 (3) DS-GVO to revoke your consent given once (also before the validity of the DS-GVO, i.e. before 25.5.2018) - i.e. your voluntary will made understandable in an informed manner and unambiguously by means of a declaration or other clear confirming action that you agree to the processing of the personal data concerned for one or more specific purposes - at any time vis-à-vis us, if you have given such consent. This has the consequence that we may no longer continue the data processing based on this consent for the future and
- complain to a data protection supervisory authority about the processing of your personal data in our company in accordance with Art. 77 DS-GVO, for example to the data protection supervisory authority responsible for us: [Competent data protection supervisory authority], [address], e-mail: [e-mail address].
(13) Changes to the Data Protection Notice
In the context of the further development of data protection law and technological or organizational changes, our data protection information is regularly reviewed to determine whether it needs to be adapted or supplemented. You will be informed of any changes in particular on our German website at [www.ownership.de]. This data protection notice is current as of [November 2022].
B. Visiting Webpages
(1) Explanation of Function
You can obtain information about our company and the services we offer in particular at [www.ownership.de] together with the associated sub-pages (hereinafter collectively referred to as "websites"). When you visit our websites, personal data may be processed.
(2) Processed Personal Data
During the informative use of the websites, the following categories of personal data are collected, stored, and processed by us:
"log data": When you visit our websites, a so-called protocol data record (so-called server log files) is stored on our web server on a temporary and anonymized basis. This consists of:
- the page from which the page was requested (so-called referrer URL)
- the name and URL of the requested page
- the date and time of the request
- the description of the type, language and version of the web browser used
- the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established
- the amount of data transferred
- the operating system
- the message whether the call was successful (access status/http status code)
- the GMT time zone difference
"Contact form data": When using our contact form, the data transmitted through it are processed (e.g. gender, surname and first name, address, company, e-mail address and the time of transmission).
(3) Purpose and Legal Basis of Data Processing
We process the personal data described in more detail above in accordance with the provisions of the DS-GVO, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 (1) sentence 1 lit. f DS-GVO, the aforementioned purposes also represent our legitimate interests.
The processing of log data serves statistical purposes and to improve the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6 para. 1 p. 1 lit. a or lit. f DS-GVO).
Contact form data is processed for the purpose of handling customer inquiries (legal basis is Art. 6 para. 1 p. 1 lit. b or lit. f DS-GVO).
If the processing of data requires the storage of information in your terminal equipment or access to information already stored in the terminal equipment, Section 25 (1), (2) TTDSG is the legal basis for this.
(4) Duration of Data Processing
Third parties used by us will store your data on their system for as long as is necessary in connection with the provision of services for us in accordance with the respective order.
(5) Transfer of Personal Data to Third Parties; Basis for Justification
The following categories of recipients, which are usually order processors (see A.(7)), may receive access to your personal data:
- Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data center services, payment processing, IT security). The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. b or lit. f DS-GVO, insofar as it does not involve order processors;
- Government agencies/authorities, insofar as this is necessary for the fulfillment of a legal obligation. The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. c DS-GVO;
- Persons employed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in corporate acquisitions or the establishment of joint ventures). The legal basis for disclosure is then Art. 6 (1) sentence 1 lit. b or lit. f DS-GVO.
For the guarantees of an adequate level of data protection in the event of a transfer of data to third countries, see A.(8).
In addition, we will only disclose your personal data to third parties if you have given your express consent to do so in accordance with Art. 6 (1) sentence 1 lit. a DS-GVO.
Cookies can contain data that make it possible to recognize the device used. In some cases, however, cookies only contain information on certain settings that cannot be related to a specific person. However, cookies cannot directly identify a user.
A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, a distinction is made between cookies:
- Technical cookies: these are essential to navigate the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes, nor do they store which web pages you have visited;
- Performance Cookies: These collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect information that could identify you - all information collected is anonymous and is used only to improve our website and to find out what interests our users;
- Advertising cookies, targeting cookies: these are used to provide the website user with tailored advertising on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;
- Sharing cookies: These are used to improve the interactivity of our website with other services (e.g. social networks); Sharing cookies are stored for a maximum of 13 months.
Specifically, the following cookies are used on this website:
|_ga||Google Analytics||Registers a unique ID that is used to generate sta-tistical data about how the visitor uses the website.||2 years|
|_gat||Google Analytics||24 hours|
|_gat_eightselectPSP||Google Analytics||1 minute|
|_gid||Google Analytics||This cookie is used to distinguish between users.||24 hours|
You can prevent cookies from being stored on your hard drive by setting your Internet browser accordingly, for example by generally deactivating the automatic setting of cookies.
In some cases, you can also object to the storage of cookies by setting so-called opt-out cookies. These are cookies that are stored on your terminal device and prevent data from being collected and stored by the tools concerned. Please note that opt-out cookies are linked to the end device and browser used. If you use multiple end devices/browsers, you must therefore perform the opt-out on each individual device/browser. If you delete all cookies in your browser, the opt-out cookies will also be deleted, so that it may be necessary to perform the opt-out again.
b) Social Media Plugins
We do not use any social media plugins on our websites. If our websites contain symbols of social media providers (e.g. Facebook, Google Maps, Instagram, Open Street Map, Twitter, Vimeo or YouTube), we use these only for passive linking to the pages of the respective providers.